In the result, the appeals of the Revenue are dismissed whereas the appeal of the assessee is partly allowed and partly allowed for statistical purposes

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Penalty u/s 271(1)(c) for furnishing inaccurate particulars is initiated separately.” The above findings of Assessing Officer clearly demonstrate that Assessing Officer has made the disallowance by mechanically following the formula given in Rule 8D. The assessee during the assessment proceedings had I.T.A. No.416/Lkw/2013 I.T.A. No.752/Lkw/2016 20 I.T.A. No.772/Lkw/2016 Assessment Year:2011-12 submitted vide letter dated 20/03/2015